Pretreatment Program Quick Links
Services Offered for Pretreatment Program Components
Legal Authority
Program Implementation
Development, Assessment, Updates, and Implementation
DROP Collaborative can comprehensively create or update your Pretreatment Program including local limit calculations, legal authority, procedures and templates as described in the Program Components. DROP Collaborative assists Municipal and Industrial clients with Pretreatment Program Implementation tailored to the client’s needs, including Pretreatment Assessments to address compliance issues and evaluate Best Management Practices. We specialize in providing customized assistance in ensuring environmental and wastewater staff have the resources needed to adequately implement pretreatment programs.
Assistance can range from training to hands-on assistance with implementation. DROP Collaborative will participate in industrial inspections and review industrial user reports for compliance.
We specialize in providing communities and their industrial customers with the tools needed to maintain compliance with Pretreatment Program requirements.
Services Offered for Pretreatment Program Components
DROP Collaborative will evaluate the need to update local limits based on changes since the local limits were developed. DROP Collaborative stresses the importance of monitoring the community’s influent loading to confirm loading from current industries and potentially unidentified industries. DROP Collaborative also provides detailed local limit updates which incorporate analytical data from domestic background and biosolids; DROP Collaborative strives to provide a realistic understanding of the impact of industrial discharges on a community’s wastewater system.
Includes required and recommended sampling on an annual basis so that local limit evaluations can be performed after each permit renewal. Flexibility of also summarizing MSOP/NPDES permit requirements or just focusing on pretreatment. Communication with contract labs on required reporting limits. Incorporates/takes advantage of sampling already required in the permit (e.g., expanded effluent tests and annual biosolids tests). DROP Collaborative also strives to understand pollutants of concern for each industry; regulations for the industries are frequently outdated and federal standards do not necessarily identify the appropriate pollutants of concern.
DROP Collaborative can assist in evaluating new (or newly identified) industries to determine whether they fall under a categorical standard or are otherwise significant industrial users. DROP Collaborative works to ensure permit applications contain the necessary information to be able to fully evaluate industries so that permits can be developed which are appropriate for the industry’s ability to impact your POTW.
DROP Collaborative-developed Industrial User permits include fact sheets to document the permit decision-making process which includes identification of pollutants of concern, monitoring frequencies, monitoring locations, limits, and sample types. DROP Collaborative permits also include the development of self-monitoring report templates to give the industries a template which helps ensure compliance with the program requirements (certification statements, discharge volume documentation, compliance with numerical results, etc.). DROP Collaborative can calculate production-based standards and incorporate that into the permit requirements.
Streamlined procedure which uses a federal database, water records, Google Maps with facility locations and summarized data, elimination process, and one-page survey to narrow down the list of industries. DROP Collaborative recommends a survey be performed before each local limit evaluation (to confirm the industrial flows).
DROP Collaborative can provide Industrial clients with a Pretreatment System Evaluation including: site inspections to assess regulatory compliance, condition and reliability of pretreatment equipment and processes, life-cycle cost analysis, pollutant removal efficiency, and potential failure risk of current pretreatment operations; gather data to analyze pretreatment efficacy and identify analytes present; and recommend solutions to compliance issues and implement Best Management Practices.
Legal Authority
When legal authority to regulate nondomestic discharge is missing or outdated, enforcement stalls, and the utility absorbs the risk. DROP Collaborative’s recommendations align your sewer use ordinance with state and federal pretreatment program requirements and incorporate intentional modifications for improved protection of the wastewater system. Common updates include authorizing cost recovery, removing redundant and conflicting provisions, and adding flexibility to control nondomestic discharges. DROP Collaborative can provide your utility with recommended code language, a submittal package for the Approval Authority, a plain-language summary of what changed and why, and support carrying it through adoption.
DROP Collaborative develops ERPs that combine administrative guidance with a software solution for identifying, documenting, and responding to user noncompliance. Our approach is built on score-based escalation: violations are scored, and the score drives the response. This enables enforcement escalation to be consistent across the jurisdiction, while still leaving room for the professional judgment of utility staff. The result is a faster return to compliance and a defensible record.
Program Implementation
Lunch ‘n Learn to provide training to Industries and pretreatment/administrative personnel: Includes background on what a pretreatment program is, what the City has to do, and what the industry requirements are. Review common errors/omissions historically observed by the industries.
DROP Collaborative has developed and continues to develop standard forms for the implementation of Pretreatment Programs. These forms include permit applications, TTO waiver processes, plant closure procedures, and templates for public notification of significant noncompliance.
